Film Advertising Rules in Singapore: When a Video Ad on a Public Screen Needs IMDA Classification

Last updated 26 September 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Film classification in Singapore is administered by the Infocomm Media Development Authority under the Films Act 1981. Where a campaign’s classification status is unclear, the question goes to IMDA or a lawyer before the media is booked.

Under Singapore law, the fifteen-second video you made for a mall screen is a film.

Not metaphorically. Section 2 of the Films Act 1981 defines a “film” as a cinematograph film or video recording, a video game, or “any other form of recording from which a moving visual image … can be produced and viewed”, and says expressly that it “includes any trailer for a film and any part of a film”. A brand commercial, a product demo loop, a looping social cut on an LED wall and a trailer for an event are all films within that definition.

That matters because the Films Act makes it an offence to publicly exhibit an unclassified film, and most marketers assume — usually correctly — that commercials are exempt. The exemption exists. But it is conditional, the conditions are content-based, and several of them were rewritten in 2026. This article sets out when a Singapore video ad genuinely needs IMDA classification, and the separate prior-approval rule that applies to posters and standees for films.

The offence: publicly exhibiting an unclassified film

Section 21(1) makes it an offence to distribute or publicly exhibit an unclassified film, or to possess one intending to do so, where the person knows, ought reasonably to have known, or is reckless as to whether it is unclassified. Under section 21(8)(a) the maximum is a fine of $40,000 or six months’ imprisonment, or both.

“Publicly exhibit” is defined as exhibiting the film in a public place, or so that it can be seen from a public place — and it includes arranging or conducting the exhibition and having the superintendence or management of the place from which it is exhibited. So the people potentially in the frame are not just the advertiser but the agency that booked the screen and the landlord or operator that runs it.

A “public place” is any place in Singapore to which members of the public have access, “whether or not on payment of a fee”, and any part of a place the occupier allows the public into while it is ordinarily open. A shopping mall concourse, a retail store, a showroom, an MRT concourse, an event hall with a ticketed audience, a roadshow atrium and a café all qualify. A screen facing a street qualifies because it can be seen from a public place.

The line that matters most: online versus public screens

Before going further, the single most useful fact in this article. Paragraph 5(2) of the Films (Classification — Exempt Films Other than Video Games) Notification 2019 provides that section 21(1) “does not apply in respect of the distribution by electronic transmission of any film”.

In practice, that means the unclassified-film offence is not the regime that governs your YouTube pre-roll, your Meta Reels ad or the video on your website. Those have their own rulebooks — platform policies, the ASAS code, and sector rules like the ones in our guides to health product advertising and tobacco and vape advertising. Our guide to video for social ads covers that side.

The exemption is for distribution by electronic transmission. It says nothing about public exhibition. The moment the same file plays on a screen in a public place, section 21(1) is back in play unless the film is exempt or classified. The same asset can be outside the offence on Instagram and inside it on a mall LED wall. That asymmetry is what this article is really about.

Surfaces where a Singapore video ad is typically publicly exhibited:

• Digital out-of-home screens: mall LED walls, lift-lobby screens, bus-stop and street-facing panels.
• In-store and showroom screens, including window-facing displays.
• Roadshow, pop-up and exhibition booth screens.
• Event screens, including conferences, launches and brand activations with public or ticketed entry.
• Cinema pre-show advertising.

The commercials exemption — and its two conditions

Section 21(10) excludes “exempt films” from the meaning of unclassified film, and paragraph 5(1) of the Notification confirms that section 21(1) does not apply to the public exhibition of an exempt film. Paragraph 3(1)(l) lists the category most advertising relies on: a film consisting wholly of an advertising program or a commercial that:

• promotes or is designed to publicise any goods (including a film), any brand of products or services, but not any health-related goods or services; or
• promotes or is designed to publicise any event which is not a cause-related event.

That exemption then carries a second condition that applies to every category in paragraph 3: the film must not contain any “impermissible material”. So a commercial is exempt only if it passes two tests — what it promotes, and what it contains. Fail either and it is an ordinary film that needs classification before it can be publicly exhibited.

Test one: what it promotes — health, and since May 2026, tobacco and vapes

The Notification defines “health-related goods or services” as:

• any health product within the meaning of the Health Products Act 2007;
• any service relating to the treatment of any ailment, disease, injury, infirmity or condition affecting the human body, the advertising of which is regulated under the Medicines (Advertisement and Sale) Act 1955 or any other written law; and
• any tobacco product, imitation tobacco product or vaporiser within the meaning of the Tobacco and Vaporisers Control Act 1993 — inserted by S 264/2026 with effect from 1 May 2026.

So a clinic, aesthetic practice, pharmacy, supplement brand, medical-device retailer or TCM service cannot rely on the commercials exemption for a video played on a public screen. Its video is a film that needs classification first. That sits on top of, not instead of, the content rules in the healthcare and health-product advertising regimes.

Test two: what it contains — the impermissible-material list

Paragraph 3(2) defines impermissible material. Read it as a creative brief, because every item is something agencies routinely put in ads:

And paragraph 3(3) adds one more for public exhibition only: any dialogue or commentary, in whole or part, in a Chinese dialect other than Mandarin. A heartland campaign with a Hokkien or Cantonese voiceover may be fine on social media and still lose the exemption on a mall screen.

Note the drafting of limb (c): it is “any depiction or description“, not promotion. An alcohol brand’s ad that shows someone drinking is caught; so, on its face, is an ad for an unrelated product that happens to include a scene with a drink in hand at a party. The S 264/2026 amendment added vaporiser use and psychoactive substance abuse to this limb, with effect from 1 May 2026.

Posters, standees and banners for films: the prior-approval rule

The second half of the regime runs the other way. It is not about ads that are films; it is about ads for films.

Section 22A(1) provides that every advertisement for a film that is intended for distribution or public exhibition must be submitted to the Authority for approval. IMDA may approve it with or without conditions, or refuse, and may revoke an approval if the film becomes unclassified or is re-classified. Section 22 then makes it an offence to publish a disapproved or revoked advertisement, to publish an approved advertisement in a different form, or to publish it other than in accordance with its conditions — each carrying a fine of up to $5,000.

What counts as an “advertisement for a film” is narrower than it first appears. Section 2 includes words, still pictures, signs, symbols and visual images used to publicise a film or promote its distribution or public exhibition — the Act’s examples are a flag, poster, placard, banner, photograph, sketch or signboard, and packaging. But it expressly excludes:

• a trailer;
• an advertisement in a book, newspaper, periodical or magazine;
• a catalogue or price list;
• an advertisement on clothing or apparel;
• a website advertisement;
• an advertisement that is broadcast; and
• personal opinion communicated by an individual for no commercial gain.

So the approval requirement bites on physical and out-of-home material: the cinema standee, the mall banner, the bus-stop poster, the festival signboard, the printed flyer. Section 22(5) adds further carve-outs, including advertisements for films not distributed or exhibited in Singapore, merchandise products that a reasonable person would not treat as a primary source of classification information, advertisements for exempt films, and trailers that are classified films.

IMDA takes submissions through a FormSG form, “Submission of Print Advertisements for Films”. It asks for five things: the film title, the places or publications where the advertisement will appear, the display dates, the dimensions, and a clear picture of the advertisement. That is a short form — but it means the media plan (locations and dates) must be settled before approval can be sought, which is the reverse of how most campaigns are run.

Separately, section 18(3)(c) requires every classification certificate to state the conditions about the display of the classification rating and consumer advice on any advertisement of the film. The rating is not optional decoration on the poster; it is a certificate condition.

Trailers are films in their own right

Because the definition of film includes “any trailer for a film”, a trailer shown on a public screen is itself a film that must be classified or exempt. The ad-approval rule then steps aside for classified trailers (s 22(5)(e)), since the classification process has already reviewed them. For a distributor, a festival or a venue running trailers in a lobby, the sequence is: classify the trailer, then exhibit it; do not treat it as advertising collateral that sits outside the classification system.

Worked examples

1. A craft beer launch on a mall LED wall. The brand’s thirty-second spot shows friends clinking glasses and drinking at a hawker centre. On Instagram, the unclassified-film offence does not apply. On the mall screen, the exemption fails at paragraph 3(2)(c) — depiction of alcohol consumption — so the spot needs classification before it runs. The fix is either to classify it, or to cut a public-screen version that shows the product, the pour and the setting without consumption.

2. An aesthetic clinic’s in-store video. A clinic plays a before-and-after treatment loop on a street-facing window screen. The commercials exemption is unavailable at the first test: the service relates to treatment of a condition affecting the body and its advertising is regulated. The video is a film that needs classification before it is publicly exhibited — and its content must separately satisfy the healthcare advertising rules.

3. A retailer’s festive campaign. A department store cuts a video for its Deepavali or Christmas campaign that directly references the religious festival. Paragraph 3(2)(b) excludes “any reference to any religious event”, so the public-screen version may need classification even though the same content would face no Films Act issue online. A version built around seasonal shopping, gifting and décor rather than the religious observance itself avoids the question.

4. A CSR film at a mall activation. A bank screens a short film supporting a mental-health awareness campaign at a roadshow. Paragraph 3(2)(g) catches “publicising a cause or campaign”, and paragraph 3(1)(l) excludes cause-related events. Classify it. Our guide to charity fundraising marketing covers the other rules on cause-led appeals.

5. An indie film screening at a café. The organiser prints an A1 poster and a standee. Both are advertisements for a film under section 2, so both must be submitted through IMDA’s form before display, with the title, location, dates and dimensions. An Instagram post for the same screening is a website-type advertisement outside the approval requirement — although the film itself still needs to be classified or exempt before it is publicly exhibited at the café.

Events: where production teams get caught

Event video is the most common way an SME ends up publicly exhibiting a film without thinking of it that way. A launch sizzle reel, a sponsor loop on a stage screen, an awards-night montage and a roadshow booth video are all films shown in places the public can enter. Most will be exempt commercials. But event content is exactly where impermissible material creeps in: a toast on stage, a religious blessing in a corporate anniversary video, a political figure in a “year in review”, a charity segment, a dialect-speaking comedian in the MC reel.

The practical rule for production teams: when an asset is going to a public screen, review it against paragraph 3(2) as a separate step from creative approval. Our guide to event videography covers the production side, and our guide to planning a corporate video is the right place to add a classification check to the brief.

Penalties at a glance

A public-screen checklist

• Tag every asset by destination: online only, or public screen. The analysis differs.
• For public screens, run the two exemption tests: does it promote health, tobacco, vapes or a cause; and does it contain anything on the paragraph 3(2) list, or dialect dialogue?
• Cut a public-screen version rather than classifying, where the offending element is incidental.
• Re-check on every re-edit. A new scene can remove the exemption.
• For film posters and standees, fix locations and dates first, then submit through IMDA’s form before printing.
• Classify trailers before playing them in lobbies, at festivals or on public screens.
• Tell the screen operator what you have checked — their management of the place brings them within “publicly exhibit” too.

Frequently asked questions

Do video ads in Singapore need IMDA classification?
Most do not. A commercial promoting goods, a brand or a non-cause event is an exempt film under paragraph 3(1)(l) of the Films (Classification — Exempt Films Other than Video Games) Notification 2019, provided it does not promote health-related goods or services and contains no impermissible material. A commercial that fails either test needs classification before it is publicly exhibited, for example on a mall screen.

Does the Films Act apply to YouTube or social media ads?
The offence of distributing or publicly exhibiting an unclassified film in section 21(1) does not apply to distribution by electronic transmission, under paragraph 5(2) of the Exempt Films Notification. Online video ads are governed by platform policies and sector advertising rules instead. The position changes when the same video is shown on a screen in a public place.

What content makes a commercial lose its exemption?
Impermissible material under paragraph 3(2) includes matter offensive to a race or religion, any reference to a religious event, any depiction of gambling, smoking, vaporiser use, alcohol consumption or unlawful conduct, sexual content including titillating attire, coarse language or frightening sequences, political references, and cause or campaign messaging. For public exhibition, dialogue in a Chinese dialect other than Mandarin is also impermissible.

Do film posters need approval in Singapore?
Yes. Section 22A of the Films Act requires every advertisement for a film intended for distribution or public exhibition to be submitted to IMDA for approval, and IMDA accepts submissions through a FormSG form. Trailers, press advertisements, website advertisements, broadcast advertisements, apparel and catalogues are excluded from the definition. Publishing a disapproved or altered advertisement carries a fine of up to $5,000.

What changed in 2026?
S 264/2026 amended the Exempt Films Notification so that, from 1 May 2026, tobacco products, imitation tobacco products and vaporisers count as health-related goods, which cannot use the commercials exemption, and depictions of vaporiser use and psychoactive substance abuse count as impermissible material.

The takeaway

Singapore’s film law touches advertising at two points, and most marketers only ever think about the first. The first is whether the ad itself is a film that needs classification — and for ordinary brand commercials the answer is no, provided they stay clear of health products, causes and a specific list of content. The second is whether a poster or standee for a film needs IMDA’s approval — and for physical, out-of-home material the answer is yes, every time.

The detail worth remembering is the online asymmetry. Because electronic distribution sits outside the unclassified-film offence, a campaign can be entirely compliant on social media and still have a problem on a mall screen. That makes the destination of each asset, rather than the creative itself, the first question on a Singapore video brief.

If you are producing video for public screens, events or cinema in Singapore, our video production team builds the destination check into the brief from the start; see our client case studies. Start with our complete guide to corporate video in Singapore, and read it alongside our guide to gambling advertising rules, which covers the other regime where a depiction on screen can become an offence.